Results 15,701-15,720 of 26,685 for speaker:David Cullinane
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: I am not looking for the figures. I am asking whether it is to do with how their taxes were calculated or to do with write-downs, incentives and so on.
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: Forgive me if I am wrong, but was the judgment not that there was a special arrangement for Apple in terms of state aid rules which did not apply to other companies? Was that not the substance of the Directorate General's judgment? Perhaps the Department might have an answer to that question.
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: It is not that tricky because the judgment was very clear. The judgment was that favourable treatment was given to Apple. Was that not the essence of the Commission's judgment?
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: It was made in terms of state aid.
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: And the Department is appealing that judgment.
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: I am just trying to understand the calculations. If all state aid which was given to those two Apple companies is being calculated, I would imagine that similar state aid was given to other companies, was it not? I am trying to establish what exactly the Department is looking at to arrive at whatever figure it will arrive at. I am sure it will be greater than €13 billion. Is it...
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: Perhaps I can put if differently to help the witnesses understand me. I put this question to Mr. Cody. The judgment is that the State did not collect enough tax from Apple. That judgment was because of what the Commission saw as favourable state aid rules being applied to Apple, a special arrangement or whatever way one chooses to phrase it. That was the substance of its judgment, which...
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: I understand that.
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: Yes, I understand that.
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: However, Revenue is obviously using a methodology to calculate this figure.
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: Will Mr. Cody explain that methodology to me?
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: I appreciate that. I understand the point that Mr. Cody is making that, although this ruling will be tested in the court, it is a decision of the Commission and Revenue can only calculate a figure in respect of the two companies before it on the basis of that decision. I am just surmising that if a similar exercise were carried out on other companies using the same methodology, it is...
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: I am not asking Revenue to do it, I am-----
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: I will finish with the special report of the Comptroller and Auditor General. There is a quote which has been dealt with but on which I have some questions, "eight of the 100 companies with the highest taxable income had an effective tax rate of zero, including some who had negative rates", which are cases in which rebates were paid, "A further five had an effective rate of less than 1%."...
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: They would have paid tax in the other country.
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: I want to go through very quickly some of the allowances that are available. In the briefing document received by members, much of the information is about the tax treatment of intellectual property. The first one is the capital allowances for intellectual property. What are those allowances for a company?
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: What is the current position on that? There were changes, I believe in 2014, where the 80% cap was abolished but was brought back again. What is the current position?
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: Okay, it the 80% cap is back again. With regard to the other capital allowances, what other allowances are available?
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: One is 7% of the expenditure on an intellectual property asset for each year over 14 years, followed by a 2% reduction in year 15. Is that one of the allowances?
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: I am looking at it now. There are capital allowances for intellectual property and tax relief for expenditure on research and development and I believe this was dealt with by a previous speaker earlier. Is the knowledge development box, KDB, separate?